Amendments to the NILLTPFNL Law – What Changes Are Being Introduced Regarding Beneficial Owners in 2026?
On December 3, 2025, Saeima adopted significant amendments to the Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing (NILLTPFNL). The amendments will take effect in two phases – on April 1, 2026, and July 1, 2026.
On April 1, the most extensive set of changes affecting all entities subject to the NILLTPFN came into force. The most significant changes include a new mandatory beneficial owner (UBO) data element, “scope of control,” and a mechanism to restrict public access to UBO data for security reasons. Starting from July 1, the Register of Enterprises (the Register) will record all UBO nationalities, if there are multiple. Below is a detailed overview of the changes.
What specifically is changing?
To fully implement the requirements of Articles 11, 12, 13, and 15 of Directive No. 2024/1640, Article 183of the NILLTPFNL has been amended. The scope of information that must be disclosed in the Register regarding UBO has been expanded. This includes: all nationalities, if there are multiple, as well as the extent of control exercised. Additionally, the UBO gains the right to request that public access to information about themselves be restricted in cases where the disclosure of such information could pose a threat to life, health, or property of the UBO or their family members.
Information Redaction – A New Protection Mechanism
A UBO has the right to submit an application to the Register to have information about them as a UBO designated as restricted-access information. An application may be submitted if the public availability of the information could put this person or their family members at risk of being subjected to a criminal offense and there are objective grounds to believe that this risk could materialize, endangering their:
- life;
- health;
- property.
Upon receiving an application, the Register shall immediately, but no later than within one business day, redact the relevant UBO information without issuing a separate decision. The information shall remain redacted for the duration of the application review – one month from the date of receipt.
Important: The UBO is required to immediately inform the Register if the threat no longer exists. However, if the threat persists, confirmation of its continuation must be submitted once a year.
How does the information redaction process work in practice?
The UBO submits an application to the Register, providing a detailed description of the information and, if available, attaching evidence, confirming the information provided in the application regarding the existing threat. The application may be submitted both upon the registration of a new legal entity and in cases where information about the UBO has already been published.
The Register reviews the application and, if necessary, has the right, but not the obligation, to request the opinion of other authorities regarding the circumstances and the potential realization of the threat. The Register issues a decision, which may be contested – either with the Chief State Notary of the Register or appealed in court in accordance with the procedures set forth in the Administrative Procedure Law. Please note that if the initial decision is in favor of not withholding information and the temporary protection is terminated, then challenging or appealing it does not reinstate the temporary protection.
If the decision is made in favor of withholding the information, it will be withheld both in the section on the UBO of a sole proprietorship or a capital company and in the section where the relevant UBO is listed as an owner or participant (shareholder). Furthermore, if the UBO status arises from indirect ownership rights (indirect participation), the information will be redacted in the sections where the UBO is a member (shareholder) and which relate to that person’s status as a UBO.
It is important to note that the redaction of information applies only to UBO data. It does not apply to information regarding members (shareholders) in capital companies where the specific person is not identified as a UBO. Similarly, the withholding of information does not apply to data registered under another status of the person, for example, as a person authorized to represent a capital company or as the owner of a sole proprietorship.
Updating Nationality Data
Individuals who have been assigned a Latvian personal identification number will not need to submit a separate application to the Register to update information regarding their nationality or nationalities. The current information will be automatically retrieved from the Register of Natural Persons. However, if a Latvian personal identification number has not been assigned, updated information regarding the UBO’s nationality or nationalities must be submitted to the Register by the end of 2026. If the information is not updated within this timeframe, there are currently no penalties applicable.
Scope of control exercised by the UBO – a new data element
Going forward, in addition to information on the type of control exercised, information on the scope of control exercised will also be recorded. How will this work in practice?
The Register already records information on the owners of sole proprietorships, as well as members or shareholders of corporations, including details on the extent of a specific person’s ownership interest. In these cases, the Register will automatically – without making a separate decision – record information regarding the extent of control exercised by the UBO alongside the information on the extent of ownership recorded in the details of owners, members, or shareholders.
In cases where the Register is unable to ensure the automatic recording of such information, the relevant information must be submitted to the Register by the legal entity itself. The information must be submitted as part of the process of updating other information regarding UBO.
